Correspondent Bank Registry

ABSTRACT

Methods and systems are provided for facilitating the transfer of information relating to risk management, such as, for example information directed towards compliance with the USA PATRIOT Act and certification of a foreign correspondent bank. Generally, the a foreign bank or other entity can provide a risk management clearinghouse with information relating to compliance with government requirements, or other information, and allow the risk management clearinghouse to convey to information in whole or in part to interested parties. Centralized distribution of certification related information can facilitate consistent and accurate compliance with government related requirements.

CROSS REFERENCE TO RELATED APPLICATIONS

This application claims priority to U.S. Ser. No. 60/390,937 filed Jun.24, 2002 and entitled “Correspondent Bank Registry”. This application isa continuation-in-part of a prior application entitled “Risk ManagementClearinghouse” filed Apr. 4, 2002 and bearing the Ser. No. 10/074,583,as well as being a continuation-in-part of a prior application entitled“Risk Management Clearinghouse” filed Oct. 30, 2001, and bearing theSer. No. 10/021,124, which is also a continuation-in-part of a priorapplication entitled “Automated Global Risk Management” filed Mar. 20,2001; and bearing the Ser. No. 09/812,627, all of which are relied uponand incorporated by reference.

BACKGROUND

This invention relates generally to a method and system for facilitatingthe identification, investigation, assessment and management of legal,regulatory, financial and reputational risks (“Risks”). In particular,the present invention relates to a computerized system and method forbanks and non-bank financial institution to comply with “know yourcustomer” requirements associated with a correspondent bank.

As money-laundering and related concerns have become increasinglyimportant public policy concerns, regulators have attempted to addressthese issues by imposing increasing formal and informal obligations uponfinancial institutions. Government regulations authorize a broad regimeof record-keeping and regulatory reporting obligations on coveredfinancial institutions as a tool for the federal government to use tofight drug trafficking, money laundering, and other crimes. Theregulations may require financial institutions to file currency andmonetary instrument reports and to maintain certain records for possibleuse in tax, criminal and regulatory proceedings. Such a body ofregulation is designed chiefly to assist law enforcement authorities indetecting when criminals arc using banks and other financial institutionas an intermediary for, or to hide the transfer of funds derived fromcriminal activity.

Amongst other obligations, sections 313 and 319(b) of the Uniting andStrengthening America by Providing Appropriate Tools Required toIntercept and Obstruct Terrorism (USA PATRIOT) Act of 2001 prohibitcertain financial institutions from providing correspondent accounts toa foreign Shell Bank and requires financial institutions to takereasonable steps to ensure that a correspondent account provided to aforeign bank is not being used to indirectly provide banking services toforeign Shell Banks. In addition, section 319(b) of the USA PATRIOT Actadds a new subsection (k) to 31 U.S.C. 5318 which requires certainfinancial institutions that provide correspondent accounts to a foreignbank to maintain records of the foreign bank's owners and agent in theUnited States designated to accept service of legal process.

The USA PATRIOT Act, provides that a covered financial institution shallnot establish, maintain, administer, or manage a correspondent accountin the United States for, or on behalf of, a foreign bank that does nothave a physical presence in any country (Shell Bank). In addition, theUSA PATRIOT Act requires a covered financial institution to takereasonable steps to ensure that any correspondent account established,maintained, administered, or managed by the covered financialinstitution in the United States for a foreign bank is not being used bythat foreign bank to indirectly provide banking services to a foreignShell Bank that is not a regulated affiliate. Current regulations canrequire that a certification be established and maintained on a two yearcycle.

Bank and non-bank financial institutions, including: an investment bank;a merchant bank; a securities firm, any insured bank (as defined insection 3(h) of the Federal Deposit Insurance Act (12 U.S.C. 1813(h)); acommercial bank or trust company; a private banker; a credit union; athrill institution; broker dealers securities and commodities tradingfirms; asset management companies, hedge funds, mutual funds, creditrating funds, securities exchanges and bourses, institutional andindividual investors, law firms, accounting firms, auditing firms, orany institution the business of which is engaging in financialactivities as described in section 4(k) of the Bank Holding Act of 1956;may be subject to legal and regulatory obligations associated with theUSA PATRIOT Act, hereinafter collectively referred to as “FinancialInstitution.” Financial Institutions typically have few resourcesavailable to them to assist in establishing and maintaining necessaryrecords.

Establishing and maintaining certifications required under the USAPATRIOT ACT can be onerous to both a Financial Institution and to aforeign counterpart seeking to provide required information. Uncertaintycan surround what the certification requirements are and how to properlyfulfill them. Directions given by the U.S. Treasury Department estimatethat a qualified person may take approximately twenty hours to properlygenerate a certification. This amount of work may need to be duplicatedfor each request from each respondent bank. In addition, there exists anincreased likelihood of confusion, redundancy, inaccuracy andcontradiction if different entities acting on behalf of a singlecorrespondent bank provide certification to multiple respondentinstitutions.

What is needed is a method and system to coordinate and administer thecertification process. Compiled certification information should besituated in a known resource from which it can be conveyed to acompliance department or government entity and also be able todemonstrate to regulators that a Financial Institution has met standardsrelating to risk containment.

SUMMARY

Accordingly, the present invention provides methods and systems formanaging Risk related to a certification process through the utilizationof a risk management clearinghouse (RMC). The present invention providesfor a certification, such as the certification of a foreigncorrespondent bank addressing the USA PATRIOT Act, to be accomplished byreceiving risk management certification information from a foreign bankand storing the information in a computer server. A request forparticular certification information can be received and particularcertification information can be transmitted according to the directionof the requestor and/or the provider of the information. Informationtransmitted can include, for example, certification materials.

In facilitating the risk management process, a RMC can receive a requestto register certification information from an interested party orinstitution. Requests and information received can be docketed, ifdesired.

In another aspect, a RMC can receive a request for guidance relating toproviding certification and responding to the request. For example, insome embodiments, guidance can include ascertaining the completeness ofcertification information received or notifying appropriate parties ofadministrative obligations.

Still another aspect can include receiving updated information relatingto the certification and transmitting the updated information toappropriate parties. In addition, embodiments can also includerequesting authorization to convey information supplied by a party, suchas, for example, certification information, prior to conveying suchinformation. Records of any conveyance of information, or other actiontaken can also be archived.

Embodiments can also include receiving information descriptive of a riskmanagement certification from an entity, such as a foreign bank, and anetwork address of a resource storing a risk management certificationrelating to the entity. The network address of the resource storing therisk management certification can be conveyed responsive to a requestfor information relating to the foreign bank, or other entity describedby the risk management certification. Some embodiments can includereceiving authorization from the entity to convey the network address.

Embodiments can also include receiving notice of an updated riskmanagement certification and a network address of a resource containingan updated risk management certification. Notice of the updated riskmanagement certification and a network address of a resource containingthe updated risk management certification can be transmitted orotherwise conveyed to one or more recipients. Notification of a renewaldate can also be transmitted to one or more appropriate parties.

Other embodiments of the present invention can include a computerizedsystem, executable software, or a data signal implementing the inventivemethods of the present invention. The computer server can he accessedvia a network access device, such as a computer. Similarly, the datasignal can be operative with a computing device, and computer code canbe embodied on a computer readable medium.

Various features and embodiments are further described in the followingfigures, drawings and claims.

DESCRIPTION OF THE DRAWINGS

FIGS. 1 and 1 b illustrate block diagrams of some embodiments of thepresent invention.

FIG. 2 illustrates a network of computer systems that can embody acorrespondent bank registry.

FIG. 3 illustrates a flow of exemplary steps that can be executed whileimplementing some embodiments of the present invention.

FIG. 4 illustrates a flow of exemplary steps that can be executed whileimplementing other embodiments the present invention.

FIG. 5 illustrates a flow of exemplary steps that can be executed whileimplementing updates in some embodiments the present invention.

FIG. 6 illustrates a flow of exemplary steps that can be executed whileimplementing embodiments the present invention utilizing a designatednetwork address to locate a resource.

FIG. 7 illustrates a flow of additional exemplary steps that can beexecuted while implementing embodiments the present invention utilizinga designated network address to locate a resource.

FIG. 8 illustrates an exemplary graphical user interface that canimplement various aspects of the present invention.

FIG. 9 illustrates an exemplary data structure that can be utilized toimplement certain aspects of the present invention.

DETAILED DESCRIPTION

The present invention includes a method and system for facilitating thetransfer of information relating to risk management, such as, forexample, information directed towards compliance with the USA PATRIOTAct and certification of a foreign correspondent bank. Generally, aforeign bank or other entity can provide a RMC with information relatingto compliance with government requirements, or other information, andallow the RMC to convey to information in whole or in part to interestedparties. Centralized distribution of certification related informationcan facilitate consistent and accurate compliance with governmentrelated requirements.

Referring now to FIG. 1 a block diagram of one embodiment of the presentinvention is illustrated. In addition to other services that an RMCsystem 106 may provide, such as those described in related documents, anRMC system 106 can facilitate an exchange of information required tomanage risk associated with a foreign bank 101-103 and regulatedaffiliate 104. In some embodiments, an RMC system 106 can act as aregistry of information required for certification of a foreigncorrespondent bank according to risk management procedures, such as, forexample, procedures required to meet obligations set forth by the USAPATRIOT Act. The RMC system 106 can receive and maintain certifications105 responsive to the risk management procedures and make thecertifications 105 available to one or more Financial Institutions 107,government entities, or other Subscriber 108 or interested party. Inparticular, the certifications 105 can he useful to manage risk byfulfilling obligations set forth in the USA PATRIOT Act for a FinancialInstitution 107 acting as a respondent bank to a foreign correspondentbank.

For the purposes of this application, a “Shell Bank” can include aforeign hank 101-103 without a physical presence in any country. Aphysical presence can be a place of business that is maintained by aforeign bank 101-103 and is located at a fixed address, other thansolely an electronic address, in a country in which the foreign bank101-103 is authorized to conduct banking activities.

A “Correspondent Account”, with respect to a Financial Institution 107,can be an account established to receive deposits from, make payments onbehalf of a foreign Financial Institution 107, or handle other financialtransactions related to such institution.

A “Certification” 105 may be a compilation of information utilized by aFinancial Institution 107 to assist the institution to manage riskrelated to dealing with a foreign Shell Bank. Certification 105 caninclude, among other things, documentation indicating that any FinancialInstitution 107 that maintains one or more correspondent accounts in theUnited States for a foreign bank 101-103 maintain records in the UnitedStates identifying the owner(s) of such foreign bank 101-103 and thename and address of a person who resides in the United States and isauthorized to accept service of legal process for records regarding thecorrespondent account.

A Certification 105 established with the RMC system 106 can state that aforeign hank 101-103 that maintains a correspondent account with acovered Financial Institution 107 certifies either that it is not aShell Bank; that it is a Shell Bank that it is a regulated affiliate ofa non-Shell Bank; or that it is a Shell Bank that is not a regulatedaffiliate. In the case that a Shell Bank is not a regulated affiliate,prevailing law may prohibit a covered Financial Institution 107 fromestablishing or maintaining a correspondent account with that foreignbank 101-102.

Independent of a bank's or other Financial Institution's procurement ofinformation, for certification or otherwise, a RMC 106 can gather andcollect information relating to a Financial

Institution. Information can be collected, for example, from publicsources, such as government lists. Non-public information gathered by asubscriber 107-108 can also be collected and stored in a manner thatwill not violate prevailing law, such as, for example, in a ProprietaryRisk Management Server 211. In some cases, the information may supportor contradict information provided by a certification, such as whether abank 101-102 is a Shell Bank.

Amendments to the anti-money laundering provisions of the Bank SecrecyAct (BSA), which are included in the USA PATRIOT Act may require that aFinancial Institution 107 manage risk relating to correspondent accountsby ascertaining certain minimum information relating to the FinancialInstitution's 107 customers. In particular, a Financial Institution 107may manage risk relating to correspondent accounts by certifying that itis not providing correspondent accounts to foreign Shell Banks andtaking reasonable steps to ensure that a correspondent account providedto a foreign bank 101-103 is not being used to indirectly providebanking services to a foreign Shell Bank. Risk management procedures fora Financial Institution 107 that provides a correspondent account to aforeign bank 101-103 can include maintaining records relating to theforeign bank's 101-103 owners as well as records of an agent in theUnited States designated to accept service of legal process.

Risk management procedures implemented by a Financial Institution 107may dictate, for example, that the Financial Institution 107 should notestablish, maintain, administer, or manage a correspondent account inthe United States for, or on behalf of Shell Bank. In addition, the riskmanagement procedures may include taking reasonable steps to ensure thatany correspondent account established, maintained, administered, ormanaged by a covered Financial Institution 107 in the United States fora foreign bank 101-103 is not being used by that foreign hank 101-103 toindirectly provide banking services to a foreign Shell Bank that is nota regulated affiliate.

A foreign bank 101-103 can certify, such as, for example, to the RMC106, that it is not a Shell Bank. Risk management procedures can requirethat the RMC receive certification specifying a physical address for theforeign bank 101-103 and a regulator for the foreign bank 101-103. If aforeign bank 101-103 certifies that it is a regulated affiliate, theforeign bank 101-103 can be required to specify a name and address of anon-Shell Bank with which the foreign bank 101-103 is affiliated and aregulator for the non-Shell Bank and the regulated affiliate.Certification information received by the RMC 106 can be stored andorganized for expeditious delivery to an interested party authorized byparties involved to receive the information.

A foreign hank 101-103 can also certify either that it does not providebanking services to any foreign Shell Bank, other than a regulatedaffiliate; or that it provides banking services to a foreign Shell Bankbut will not use any of the correspondent accounts with a U.S. FinancialInstitution 107 to provide banking services to any foreign Shell Bank,other than a regulated affiliate.

In another aspect, a foreign bank 101-103 can certify the identity ofits owner(s) and include street addresses, as well as the identity andaddress of its agent for service of legal process in the United States.

A foreign bank 101-103 can also certify that it will notify eachFinancial Institution 107 in the United States at which it maintains acorrespondent account in writing within 30 calendar days of any changein facts or circumstances previously certified or contained in theannexes to the Certification 105.

In some embodiments, the RMC system 106 can be utilized to effectnotice, of any change in facts or circumstances previously certified orcontained in the annexes to the Certification 105. For those FinancialInstitutions 107 on record with RMC system 106 notice can beaccomplished via delivery of an electronic document, printing remotely,facsimile, or hardcopy generated and physically delivered. A RMC system106 can also be utilized to notify appropriate parties of administrativeobligations such as, for example, notice of a change in facts containedin a Certification 105.

Embodiments can also include providing a copy of any certifications 105to the Secretary of the Treasury and the Attorney General of the UnitedStates, or their delegates.

Risk management procedures can establish that reporting informationrequired for Certification 105 is voluntary for a foreign bankinginstitution 101-103; however, failure to provide information necessaryto complete Certification 105 may preclude the establishment orcontinuation of correspondent accounts with the U.S. FinancialInstitution 107.

A subscriber 107-108 can include a Respondent Financial Institution 107or other subscribing entity 108, including, for example: a regulator, amoney transfer agency, bourse, an institutional or individual investor,an auditing firm, a law firm, any institution the business of which isengaging in financial activities or other entity or institution who maybe involved with a financial transaction or other business transactionor any entity subject to legal and regulatory compliance obligationswith respect to money laundering, fraud, corruption, terrorism,organized crime, regulatory and suspicious activity reporting,sanctions, embargoes and other regulatory risks and associatedobligations.

Financial investments can include investment and merchant banking,public and private financing, commodities and a securities trading,commercial and consumer lending, asset management, rating ofcorporations and securities, public and private equity investment,public and private fixed income investment, listing to companies on asecurities exchange and bourse, employee screening, auditing ofcorporate or other entities, legal opinions relating to a corporate orother entity, or other business related transactions.

FIG. 1A illustrates a scenario wherein a respondent FinancialInstitution 107 or other subscriber 108 can receive a Certification 105from one or more foreign banks or affiliates 101-104 via an RMC 106.Certifications 105 registered with the RMC system 106 can be readilyaccessible to the respondent Financial Institution 107 or othersubscriber 108 thereby facilitating collection of certifications 105,wherein the respondent Financial Institution 107 is relieved of havingto ascertain a correct person to contact within each foreign bank101-104 from which it requires Certification 105 and coordinate receiptof each Certification 105. As illustrated, the present invention canmake it possible for the respondent Financial Institution 107 to onlyhave to complete a single access to the RMC system 106 in order toreceive multiple certifications 105, each from a separate foreign hank101-102 or from a non-shell Foreign Bank 103 and/or a regulatedaffiliate 104. The Certification 105 can contain, information to assista U.S. Financial Institution 107 comply with prevailing law regardingcorrespondent accounts and other regulations.

Embodiments can include information that is received from a foreign bank101-104 in any form that can accurately convey information necessary tocomplete the Certification 105. For example, information can he inputinto a graphical user interface (GUI), submitted via hard copy,facsimile, scanned image, or any other form of information conveyance.The RMC system 106 can store the Certification 105 and convey it uponrequest.

Similarly, Certification 105 information can be retrieved by arespondent Financial Institution 107 or other subscriber 108 using anyavailable mechanism for conveying information, including, but notlimited to: scanned image, database record retrieval, text file,facsimile, hard copy, data stored on a computer readable medium, orother mechanism.

FIG. 1B is related to FIG. 1A and more clearly illustrates a scenariowherein a correspondent Foreign Bank 101 seeking to open a correspondentaccount can convey a Certification 105 to one or more respondentFinancial Institutions 107 and 109 or other subscriber 108. In someembodiments, the correspondent Foreign Bank 101 can transmit informationrelating to the certification 105 to the RMC system 106. The RMC system106 can store the information and generate a certification 105 andconvey it to a respondent Financial Institution 107 and 109 or othersubscriber 108 upon request of the correspondent Foreign Bank 101 or theFinancial Institution 107 and 109 or other subscriber 108. Embodimentscan also include transmission of a completed certification 105 to theRMC system 106, such as an image documents comprising the certification105. The completed certification 105 can then be transmitted by the RMCsystem 106 to a Financial Institution 107 and 109 or other subscriber108.

Referring now to FIG. 2, a network diagram illustrating one embodimentof the present invention is shown 200. An automated RMC system 106 caninclude a computerized RMC server 210 accessible via a distributednetwork 201 such as the Internet, or a private network. A user 206-209,can use a computerized system or network access device 202-205 toreceive, input, transmit or view information processed in the RMC server210. A protocol, such as, for example, the transmission control protocolinternet protocol (TCP/IP) can be utilized to provide consistency andreliability.

In addition, a proprietary risk management (PRM) server 211 can accessthe RMC server 210 via the network 201 or via a direct link 213, such asa T1 line, digital subscriber line (DSL), or other high speed pipe. ThePRM server 211 can in turn be accessed by an affiliated user via asystem access device 202-205 and a communications network 201, such as alocal area network, or other private network, or even the Internet, ifdesired. For the purposes of this application, any function or referenceto an RMC server 210 can also include a PRM server 211, except that thePRM server 211 may be more appropriate to store and access proprietaryinformation that will not be shared outside of an organization except asallowed by prevailing applicable law. In addition, in some embodiments,a PRM server 211 may he utilized to calculate risk quotients or othersubjective valuations which an RMC server 210 may be limited from doingby an RMC 106 provider.

A system access device 202-205 used to access the RMC server 210 caninclude a processor, memory and a user input device, such as a keyboardand/or mouse, and a user output device, such as a display screen and/orprinter. The system access devices 202-205 can communicate with the RMCserver 210 to access data and programs stored at the respective RMCserver 210. A system access device 202-205 may interact with the RMCserver 210 as if the RMC server 210 were a single entity in the network200. However, the RMC server 210 may include multiple processing anddatabase sub-systems, such as cooperative or redundant processing and/ordatabase servers that can be geographically dispersed throughout thenetwork 200.

The RMC server 210 can include one or more databases 212 storing datarelating to risk management, and in particular to certification of aforeign bank 101-103 or affiliate 104, including, for example, docketinginformation and programming capable of tracking relative dates andentities involved. Information relating to and included in gatheredcertifications can be aggregated into a searchable data storagestructure. Gathering data into an aggregate data structure 212, such asa data warehouse, allows a RMC system 106 to have the data readilyavailable for processing a risk management search associated with aCorrespondent Bank 101-104 certification. Aggregated data 212 can alsobe scrubbed or otherwise enhanced to aid in searching.

In one embodiment of enhancing data, data scrubbing can be utilized toimplement a data warehouse comprising the aggregate data structure 212.Data scrubbing can be utilized to store information in a manner thatgives efficient access to pertinent data. Scrubbing can facilitateexpedient access to data commensurate with business decisions that willbe based upon Risk management assessment provided.

Various data scrubbing routines can be utilized to facilitateaggregation of Risk variable related information. The routines caninclude programs capable of correcting a specific type of mistake, suchas an incomprehensible address, or clean up a full spectrum of commonlyfound database flaws, such as field alignment or misplaced data and moveit to a correct field, or removing inconsistencies and inaccuracies fromlike data. Other scrubbing routines can be directed directly towardsspecific legal issues, such as money laundering or terrorist trackingactivities.

For example, a scrubbing routine can be used to facilitate variousdifferent spelling of one name. In particular, spelling of names can beimportant when names have been translated from a foreign language intoEnglish. A data scrubbing routine can facilitate risk variable searchingfor multiple spellings of an equivalent name or other importantinformation. Such a routine can help correct database flaws.Accordingly, scrubbing routines can improve and expand data quality moreefficiently than manual mending and also allow a subscriber 107-109 toquantify best practices for regulatory purposes.

Typically a user 206-209 will access the RMC server 210 using clientsoftware executed at a system access device 202-205. The client softwaremay include a generic hypertext markup language (HTML) browser, such asNetscape Navigator or Microsoft Internet Explorer, (a “WEB browser”).The client software may also be a proprietary browser, and/or other hostaccess software. In some cases, an executable program, such as a Java™program, may be downloaded from the RMC server 210 to the system accessdevice 202-205 and executed at the system access device 202-205 as partof RMC risk management software. Other implementations includeproprietary software installed from a computer readable medium, such asa CD ROM. The invention may therefore be implemented in digitalelectronic circuitry, computer hardware, firmware, software, or incombinations of the above. Apparatus of the invention may be implementedin a computer program product tangibly embodied in a machine-readablestorage device for execution by a programmable processor; and methodsteps of the invention may be performed by a programmable processorexecuting a program of instructions to perform functions of theinvention by operating on input data and generating output.

Referring now to FIG. 3, steps that can be performed while practicingthe present invention are illustrated. From the perspective of an RMCsystem 106 or RMC provider, at 310 a request to register a riskmanagement certification with the RMC system 106 can be received, suchas, for example, via an electronic communication, facsimile, hardcopy,or voice call. At 311, the RMC system 106 can convey the certificationmaterials to the entity that wishes to register or the entity's agent.The materials can be conveyed, for example, via electronic filetransfer, e-mail, facsimile, hardcopy, voice communication or othercommunications vehicle. An exemplary certification that may currently beuseful to address obligations incurred under the USA PATRIOT Act isattached hereto as Appendix A.

At 312, an RMC system 106 may receive a request for guidance inproviding the certification materials. Guidance may be necessary, forexample, to interpret obligations relating to what needs to be certifiedin order to comply with various regulatory requirements, such as thoseset forth in the USA PATRIOT Act and the relative complexity of someinformation that may need interpretation.

For example, in complying with the USA PATRIOT Act the task ofascertaining who constitutes an “owner” that should be reported can besubject to a fair amount of work and interpretation. An owner can meanany person who is a large direct owner, an indirect owner, and certainsmall direct owners. A person can mean any individual, bank,corporation, partnership, limited liability company, or any other legalentity, except that members of the same family shall be considered oneperson; and voting shares or other voting interests means shares orother interests that entitle the holder to vote for or select directors(or individuals exercising similar functions).

The USA PATRIOT Act indicates that a small direct owner may or may notneed to be reported depending on whether two or more small direct ownersin the aggregate own 25 percent or more of the voting securities orinterests of the foreign bank and are owned by the same indirect owner.A large direct owner of a foreign bank can be a person who owns,controls, or has power to vote 25 percent or more of any class of votingsecurities or other voting interests of the foreign bank; or controls inany manner the election of a majority of the directors (or individualsexercising similar functions) of the foreign bank. The identity of eachlarge direct owner is subject to reporting. If any large direct owner ofa foreign bank 101-103 is majority-owned by another person, or by achain of majority-owned persons, an indirect owner is any person in theownership chain of any large direct owner who is not majority-owned byanother person. If any two or more small direct owners of a foreign bankin the aggregate own, control, or have power to vote twenty five percentor more of any class of voting securities or other voting interests ofthe foreign bank and are majority-owned by the same person, or by thesame chain of majority-owned persons, the indirect owner can be anyperson in the ownership chain of the small direct owners who is notmajority-owned by another person. Each indirect owner may be subject toreporting.

Guidance relating to interpretation and compliance may be needed as eachforeign institution attempts to properly and consistently providecertification to each U.S. Financial Institution with which the foreigninstitution has a correspondent banking relationship. Guidance andcentralization offered by an RMC 106 can facilitate a cohesivecertification and minimize confusion, redundancy, inaccuracy andcontradictions that may result from multiple parties each interpretingand translating such guidelines on their own. In addition, the amount ofresources and administration overhead associated with maintaining suchrecords can be lessened by a centralized approach.

At 313, guidance may be provided by the RMC system 106 via onlinedocumentation, artificial intelligence programs, online question andanswer materials, live administrative assistance, referral to a thirdparty or other manner of responding to the request for guidance. Someembodiments can include guidance that ascertains the completeness ofcertification information conveyed by a foreign bank 101-104, such as,for example guidance as to whether entries have been set forth for allrequired inputs and a document has been properly executed whererequired. Electronic signatures may be sufficient in some embodiments tocomplete execution.

Embodiments can also include a verification step which can independentlyresearch the veracity of information put forth in a certification. Otherembodiments can convey any information put forth with no value judgment,research or other indication relating to the veracity or completeness ofany information conveyed in a certification.

At 314, the RMC system 106 can also receive a risk managementcertification and at 315 the certification can be stored in aretrievable data storage device. In addition, at 316 the informationdescriptive of or relating to the certification, as well as informationdescriptive of the entities involved, can be docketed. The docket can beutilized to track critical dates, entities involved, contact informationand the like. In some embodiments, docketing can include parsinginformation contained in a Certification 105 and storing the parsedinformation in a database in order to facilitate analysis and docketingof the information. For example, data can be configured to track datesrelating to the certification, dates relating to actions taken, contactinformation, requests, authorizations and other pertinent information.Other embodiments can include docketing information descriptive of aCertification 105.

At 317, the RMC system 106 can notify interested parties ofadministrative obligations, such as the obligation to re-certify everytwo years for compliance with the USA PATRIOT Act. At 318, the RMCsystem 106 can receive updated information, such as information relatedto or otherwise comprising a certificate renewal and at 319 the updatedcertification information can be transmitted to interested parties.

Referring now to FIG. 4, additional steps that can be performed whileimplementing some embodiments of the present invention are illustrated.At 410, a RMC system 106 can login an RMC subscriber and at 411 the RMCsystem 106 can receive a request for a particular certification. Thelogin can be accomplished in any manner that serves to identify thesubscriber and allow for communication between the RMC system 106 andthe subscriber, such as via login at a website or other electronicinterface. At 412, responsive to a request for a certification, the RMCsystem 106 can request authorization to convey the certification from aparty designated to grant such authorization, such as a complianceofficer for the foreign bank 101-104 for which the certification isrequested.

At 413 and 414 the RMC system 106 may receive a response to the requestfor authorization to convey the certification. At 413 a denial ofrequired authorization can be received. Accordingly, at 415 the RMCsystem 106 can transmit a denial for the request of certificationauthorization. Alternatively, at 414, the RMC system 106 may receive anapproval for the request for authorization and at 416 transmit thecertification to the requestor.

At 417, a request for a certification can be archived, along with arelated response. At 418, the RMC system 106 can also be utilized togenerate one or more reports relating to a request for certification andassociated action resultant to the request.

Referring now to FIG. 5, steps relating to updating risk managementinformation according to some embodiments of the present invention arcillustrated. Risk management information which can be updated caninclude certification information utilized to comply with the USAPATRIOT Act. At 510, a RMC system 106 can receive updated information,such as a change in contact information, change in ownership, change inagent to receive service of a subpoena or other change. At 511, thereceived updates can be docketed to facilitate in processing and at 512,a list of recipients who are to receive the updates can be compiled.Recipients can include, for example, financial institutions or othersubscribers 107-109 that have received a previous certification. At 513,updates can be transmitted or otherwise conveyed to the members includedon the list of recipients.

Referring now to FIG. 6, some embodiments of the present invention caninclude an RMC system 106 which does not actually receive riskmanagement certification information, such as a certification to complywith the USA PATRIOT Act, but instead, at 610 receives a description ofa certification 105 and a designated network address at which thecertification can be accessed. A designated network address can include,for example, a TCP/IP address, a uniform resource locator, or any otheridentifying mechanism that can direct access to a particular networkresource. At 611, the RMC system 106 can receive a request to convey aparticular certification and at 612 the RMC system 106 can requestauthorization to convey the designated network address containing theparticular certification. At 613 and 614 a denial or authorization ofthe request to convey the designated network address can be received. At613 a denial of authorization is received and accordingly, at 615 theRMC can transmit a denial of the request for the certification. At 614an approval granting authorization is received, and accordingly, at 616the RMC system 106 can transmit or otherwise convey the designatednetwork address at which the certification information can be accessed.

Relatedly, as illustrated in FIG. 7, in some embodiments, at 710, asubscriber, such as a respondent Financial Institution or other entity107-109, can request certification information from the RMC system 106and at 711 receive a designated network address of a resource thatcontains a related certification 105 which is available via the network201. At 712, a respondent Financial Institution or other entity 107-109can access a network resource located at the address conveyed by the RMCsystem 106 and at 713 receive the certification information.

Referring now to FIG. 8, an exemplary GUI 800 that can be utilized whilepracticing the present invention is illustrated. A portion of a display801 can display information that relates to a respondent Financialinstitution, such as a U.S. Bank. Another portion of the display 802 caninclude information descriptive of a correspondent Foreign Bank 101-103and any regulated subsidiaries 104. Still another portion 803 cancontain certification information. A portion 804 can also displayinstructions relating to how to obtain a certification 105.

Referring now to FIG. 9, a portion of a design of a database that can beutilized while implementing the present invention is illustrated. Thedatabase 900 can include a field containing data descriptive of arespondent Financial Institution 901 as well as a field containing datadescriptive of a correspondent institution 902. Another field can holddata descriptive of a related certification 903.

A number of embodiments of the present invention have been described.Nevertheless, it will be understood that various modifications may bemade without departing from the spirit and scope of the invention. Forexample, certified hard copy documents can be gathered and scanned intothe RMC system 106 such that the scanned image can be forwarded to asubscriber as appropriate. In addition, certification data stored withthe RMC 106 can indicate an agent for legal service which can beutilized in conjunction with an electronic subpoena service to serve asubpoena. Still other embodiments include certification data and/ordocuments that will expire and be locked, such as with encryption aftera set period of time has elapsed, such as, for example a period forwhich the data will remain current. Accordingly, other embodiments arewithin the scope of the following claims.

1. A method for managing risk associated with a correspondent account,the method comprising: receiving risk management certificationinformation from a foreign bank; storing the information in a computerserver; receiving a request for particular certification information;and transmitting the particular certification information.
 2. The methodof claim 1 additionally comprising the step of receiving a request toregister certification information.
 3. The method of claim 1additionally comprising the step of transmitting certificationregistration materials.
 4. The method of claim 1 additionally comprisingthe steps of receiving a request for guidance relating to providingcertification and responding to the request.
 5. The method of claim 1additionally comprising the step of docketing information relating tothe certification information received.
 6. The method of claim 1additionally comprising the step of ascertaining the completeness of thecertification information received.
 7. The method of claim 1additionally comprising the step of notifying appropriate ofadministrative obligations.
 8. The method of claim 1 additionallycomprising the steps of receiving updated information relating to thecertification and transmitting the updated information to appropriateparties.
 9. The method of claim 1 additionally comprising the step ofrequesting authorization to convey certification information.
 10. Themethod of claim 1 additionally comprising the step of archiving actionstaken relating to certification.
 11. A method for managing riskassociated with a correspondent account, the method comprising:receiving information descriptive of a risk management certificationfrom an entity, wherein the information received comprises a designatednetwork address of a resource storing a risk management certificationdescribed by the information; receiving a request for informationrelating to the entity described by the risk management certification;and conveying the designated network address of the network resourcestoring the risk management certification responsive to the request forinformation.
 12. The method of claim 11 additionally comprising the stepof receiving authorization from the entity to convey the designatednetwork address.
 13. The method of claim 11 additionally comprising thesteps of: receiving a notice of an updated risk management certificationand a designated network address of a network resource containing theupdated risk management certification; and transmitting the notice of anupdated risk management certification and a designated network addressof a network resource containing the updated risk managementcertification to one or more recipients.
 14. The method of claim 11additionally comprising the step of transmitting a notificationcomprising a renewal date.
 15. A computerized system for managing riskassociated with a correspondent account, the system comprising: acomputer server accessible with a system access device via acommunications network; and executable software stored on the server andexecutable on demand, the software operative with the server to causethe server to: receive risk management certification information from aforeign bank; store the information in a computer server; receive arequest for particular certification information; and transmit theparticular certification information.
 16. The computerized system ofclaim 15 wherein the server comprises a proprietary risk managementserver.
 17. Computer executable program code residing on acomputer-readable medium, the program code comprising instructions forcausing the computer to: receive risk management certificationinformation from a foreign bank; store the information in a computerserver; receive a request for particular certification information; andtransmit the particular certification information.
 18. A computer datasignal embodied in a digital data stream comprising data relating to acorrespondent account, wherein the computer data signal is generated bya method comprising the steps of: receiving risk managementcertification information from a foreign bank; storing the informationin a computer server; receiving a request for particular certificationinformation; and transmitting the particular certification information.19. A method of interacting with a network access device so as to managerisk relating to a correspondent account, the method comprising thesteps of: initiating interaction with a risk management server via acommunications network; requesting a risk management certification for aparticular foreign bank; and receiving a copy of a risk managementcertification.
 20. The method of claim 19 additionally comprising thestep of receiving an update to the risk management certification. 21.The method of claim 19 wherein the risk management certificationcomprises information asserting compliance with the USA PATRIOT Act.